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NY 816121

October 31, 1995

CLA-2-85:R:N1:104 816121


TARIFF NO.: 8515.90.2000; 8461.90.8020; 8462.39.0020

Mr. Louis Amabile
High Frequency Technology Co., Inc.
172-D Brook Avenue
Deer Park, N.Y. 11729

RE: The tariff classification of brass welding rules and bench top machine tools from Italy.

Dear Mr. Amabile:

In your letter dated October 19, 1995 you requested a tariff classification ruling.

The brass welding rules (also known as electrode rules) are pre-machined brass strips imported in fixed lengths of 67 cm for use solely in the welding or sealing of PVC and other thermoplastic materials in high frequency plastic sealing/welding machines. Thickness may range from 0.7 mm to 9.0 mm. All strips have pre-machined profiles and patterns from plain smooth surfaces to elaborate decorative and/or geometric designs. After importation, they are generally cut to length, bent to the required shape and mounted to the machine's die platen. In addition to the brass strips, you also import other machined brass geometric shapes including circles, ovals and hangers. All of these items are in effect the "tooling" for the plastic welding machines.

You also inquire about the classification of the MT1 and MT2 Cutter/Bender and the MT2 Miter/Shaver. These are hand operated bench-top units which will be used to cut and bend the pre-machined brass strips.

The applicable subheading for the brass welding rules and the geometric shapes will be 8515.90.2000, Harmonized Tariff Schedule of the United States (HTS), which provides for parts of welding apparatus. The rate of duty will be 1.9 percent.

The applicable subheading for the MT2 Miter/Shaver will be 8461.90.8020, HTS, which provides for other machine tools working by removing metal, ...: other. The subheading for the MT1 and MT2 Cutter/Benders will be 8462.39.0020, HTS, which provide for shearing machines, other than combined punching and shearing machines: other.

This ruling is being issued under the provisions of Section 177 of the Customs Regulations (19 C.F.R. 177).

A copy of the ruling or the control number indicated above should be provided with the entry documents filed at the time this merchandise is imported. If you have any questions regarding the ruling, contact National Import Specialist Robert Losche at 212-466-5670.


Roger J. Silvestri

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